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On July 26, the Centers for Medicare and Medicaid Services (CMS) informed the Medicare Administrative Contractors (MACs) that effective Jan. 1, 2020, they should accept the Appropriate Use Criteria (AUC)-related HCPCS modifiers on claims as part of an “educational and operations testing period” for the AUC Program for advanced diagnostic imaging. Claims, however, that do not include the AUC-related information will not be denied.

The transmittal comes amidst growing skepticism throughout the provider community that CMS can overcome the operational challenges that appear to be plaguing implementation of the AUC Program—a program that was created by Congress in 2014 and has become outdated as the Medicare program continues its pivot toward value-based models that put providers at risk for failing to control costs and increase, or at least maintain, quality of care.

CMS is encouraging ordering professionals to begin consulting AUC using a qualified Clinical Decision Support Mechanism (CDSM) during 2020 and providing information to furnishing practitioners and providers for reporting on their claims. But these activities come at a cost to practices even as physicians and other providers are struggling to make the investments necessary for successful participation in the Merit-based Incentive Payment System or alternative payment models.

“It's good that CMS is encouraging the consultation of AUC in 2020, but won't deny claims that don't include AUC information because operational issues persist and most physicians remain unaware of the Medicare AUC mandate,” said ASNC President Rob Beanlands, MD, MASNC .

In June, ASNC members and representatives of other physician societies were on Capitol Hill asking lawmakers to take a different approach to encouraging AUC consultation rather than the overly prescriptive and complex AUC Program.

“I don't think that Congress had any idea when it created the AUC Program its magnitude of complexity,” said ASNC Health Policy Committee Chair David Wolinsky, MD, MASNC . “There are better ways to encourage AUC consultation, and it is our job as the physician community to convey that message to lawmakers.”

In May, 22 organizations joined ASNC on a letter to CMS asking that participation in the AUC Program remain voluntary through at least 2020. That letter was followed by a meeting with high-level CMS staff who are saddled with implementing the AUC Program as Congress instructed absent legislative intervention.

“Making sure the AUC Program is not implemented as originally conceived by Congress has and continues to be a top priority for ASNC,” said Dr. Beanlands. “At the end of the day, we want to preserve the ability of cardiologists and other providers to consult ACC AUC and to do it in a manner that works best for their practice and doesn't adversely affect access to care. The AUC Program takes away that flexibility. ASNC is going to do everything it can to keep that from happening.”